IR 05000333/2005301

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Senior Reactor Operator Initial Examination Report No. 05000333/2005301
ML051940525
Person / Time
Site: FitzPatrick 
Issue date: 07/13/2005
From: Conte R
Division of Reactor Safety I
To: Ted Sullivan
Entergy Nuclear Northeast
Shared Package
ML042440205 List:
References
50-333/05-301 50-333/05-301
Download: ML051940525 (23)


Text

July 13, 2005

SUBJECT:

JAMES A. FITZPATRICK SENIOR REACTOR OPERATOR INITIAL EXAMINATION REPORT NO. 05000333/2005301

Dear Mr. Sullivan:

This report transmits the results of the Senior Reactor Operator (SRO) licensing examination conducted by the NRC during the period of May 16 to 20, 2005. This examination addressed areas important to public health and safety and was developed and administered using the guidelines of the Examination Standards for Power Reactors (NUREG-1021, Revision 9).

Based on the results of the examination, three of five Senior Reactor Operator applicants passed all portions of the examination. Two Senior Reactor Operator applicants failed the written portion of the examination. The five applicants were all instant SROs. Mr. Steven Dennis discussed performance insights observed during the examination with Mr. Rick Devercelly on May 20, 2005. On June 15, 2005, final examination results, including individual license numbers, were given during a telephone call between Mr. Richard Conte and Mr. Steve Reininghaus.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). These records include the final examination and are available in ADAMS Package Accession Number ML042440205; SRO Written - Accession Number ML051930243; SRO Operating Section A - Accession Number ML051930218; SRO Operating Section B - Accession Number ML051930227; and SRO Operating Section C - Accession Number ML051930234, and Facility Post Examination Comments on the Written Exams - Accession No. ML051930393.

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Mr. Theodore Sullivan Should you have any questions regarding this examination, please contact me at (610) 337-5183, or by E-mail at RJC@NRC.GOV.

Sincerely,

/RA/

Richard J. Conte, Chief Operations Branch Division of Reactor Safety Docket No. 50-333 License No. DPR-59

Enclosure:

Initial Examination Report No. 05000333/2005301

REGION I==

Docket No.

50-333 License No.

DPR-59 Report No.

05000333/2005301 Licensee:

Entergy Nuclear Operations, Inc.

Entergy Nuclear Northeast Facility:

James A. Fitzpatrick Dates:

May 20, 2005, Written Examination Administration May 16-19, 2005, Operating Test Administration May 19-31, 2005, Receipt of Final Licensee Post Examination Comments and Grading June 9, 2005, Examination Grading Examiners:

S. Dennis, Senior Operations Engineer (Chief Examiner)

T. Fish, Senior Operations Engineer H. Williams, Operations Engineer (Consultant)

M. Brown, Operations Engineer Approved by:

Richard J. Conte, Chief Operations Branch Division of Reactor Safety

ii Enclosure

SUMMARY OF FINDINGS

IR 05000333/2005301; May 16, 2005 to May 20, 2005; James A. Fitzpatrick; Initial Operator

Licensing Examination. Three of five applicants passed the examination (3 SRO instants).

The written examinations were administered by the facility and the operating tests were administered by three NRC region-based examiners. There were no inspection findings of significance associated with the examinations.

A.

Inspector Identified Findings No findings of significance were identified.

B.

Licensee Identified Findings No findings of significance were identified.

REPORT DETAILS

REACTOR SAFETY

Mitigating Systems - Senior Reactor Operator (SRO) Initial License Examination

a. Scope

of Review The NRC examination team developed the written and operating initial examination and together with Fitzpatrick training and operations personnel verified or ensured, as applicable, the following:

  • The examination was prepared and developed in accordance with the guidelines of Revision 9 of NUREG-1021, "Operator Licensing Examination Standards for Power Reactors. A review was conducted both in the Region I office and at the Fitzpatrick plant and training facility. Final resolution of comments and incorporation of test revisions were conducted during and following the onsite preparation week.
  • Simulation facility operation was proper.
  • A test item analysis was completed on the written examination for feedback into the systems approach to training program.
  • Examination security requirements were met.

The NRC examiners administered the operating portion of the examination to all applicants from May 16 to 19, 2005. The written examination was administered by the Fitzpatrick training staff on May 20, 2005.

b. Findings

Grading and Results Three of five applicants (SROIs) passed all portions of the initial licensing examination.

Two applicants (SROIs) passed all sections of the operating portion but failed the written portion of the initial licensing examination.

The facility had four post-examination comments on the written examination. The NRC resolutions of these comments are attached. In summary, there were two changes, one question was deleted and another had an answer change. Two licensee comments were denied. Based on these comment resolutions, the NRC regraded all of the applicants written examinations. The regrading of the written examinations did not result in the two SROI applicants achieving passing grades on the written exam.

Examination Administration and Performance No findings of significance were identified.

4OA6 Exit Meeting Summary

On June 15, 2005, the NRC provided conclusions and examination results to Fitzpatrick management representatives via telephone. License numbers for three of the five applicants were also provided during this time. Two applicants passed all sections of the operating portion but failed the written portion of the initial licensing examination and therefore denied a license at this time.

The NRC expressed appreciation for the cooperation and assistance that was provided during the preparation and administration of the examination by the licensees training staff.

ATTACHMENT 1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

LICENSEE

P. Berry, Manager, Training & Development
S. Rieninghaus, Operations Training Supervisor

Rick Devercelly, Operations Training

Donald Binkley, Operations Training

NRC

S. Dennis, Senior Operations Engineer
T. Fish, Senior Operations Engineer
H. Williams, Operations Engineer (Consultant)
M. Brown, Operations Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

ITEM NUMBER

TYPE

DESCRIPTION

NONE

ATTACHMENT 2

Licensees Post Written Examination Comments Publically Available

ADAMS Accession No. ML051930393

FITZPATRICK 2005 NRC Written Examination Post Exam Comments & NRC Resolution

The NRC staff reviewed the licensees comments for the questions below. In addition, the staff

reviewed abnormal, emergency, operating, and other pertinent procedures as noted. The

NRCs resolution for these four post exam comments is based on the independent reviews that

were conducted by both the NRC examiners assigned to the exam team as well as the Branch

Chief.

SRO Question # 40 (Licensee Comments Highlighted)

An accident has resulted in the following conditions:

Drywell Hydrogen 6%, Steady

Drywell Oxygen 2%, Steady

Torus Hydrogen 6%, Steady

Torus Oxygen 3%, Steady

Drywell Radiation 3100 R/Hr, Steady

Reactor Coolant Activity 250 uci/gm, Steady

RPV Pressure 600 psig, Lowering at 20 psig/min

Torus Pressure 55 psig, Rising at 1 psig/min

Torus Water Temperature 180° F, Rising 0.5° F/min

Torus Water Level 14 Feet, Rising 1/min

Fifteen minutes from now, the expected Control Room actions will be to:

a. Declare a Site Area Emergency. Vent and Purge the Torus and Drywell.

b. Declare a Site Area Emergency. Emergency Depressurize the Reactor Pressure Vessel.

d.

Declare a General Emergency. Evacuate a 2 mile radius and 5 miles downwind.

Answer Key:

d.

Post-Exam

Evaluation

Recommendation:

Accept both c and d as correct responses

Challenge Issue:

Required reference inadvertently omitted creating an unrealistic From

Memory expectation - The candidate should have been provided with EAP-

4, Attachment 1. Providing this reference is supported by program objective

10.02 in lesson Plan EP-12.5.4.2 which states Evaluate plant conditions and

determine PARs using EAP-4. Failure to provide the required reference

was an oversight on the part of the Exam Development Team. Both Training

Program and Station Management expectations are that Protective Action

Recommendations will not be made without first referencing EAP-4. In the

absence of the necessary reference, c is also an appropriate and

conservative response.

Candidate

Performance:

of 5 Selected d while the remaining two candidates selected c

D.

d.

CORRECT: The given conditions are 7 psig and 7 minutes from

violating the PCPL Curve. IAW EOP-4, venting of primary containment

is required prior to exceeding PCPL. General Emergency EAL 3.1.3 is

applicable when primary containment venting is required due to PCPL.

Whenever a General Emergency is declared, EAP-4 directs a Protective

Action Recommendation to evacuate a 2 mile radius and 5 miles

downwind.

A.

Incorrect: The hydrogen values given warrants a Site Area Declaration

on EAL 3.3.1. Using this rational, the hydrogen and oxygen values

given only result in vent and purge of the drywell and Torus if the

resultant off-site release rate will remain below the off-site release rate

LC

O. The values of Rx Coolant Activity and Containment Radiation, if

vented, will clearly violate the release rate LC

O. Additionally, IAP-2

directs EAL entry at the highest level indicated by the conditions.

B.

C.

Incorrect: A Site Area Emergency 3.2.1 is declared if conditions cannot

be maintained below HCTL. Although the values of RPV Pressure and

Torus Temperature are in the GREY area of the HCTL curve, they are

below that of 14 feet and trending parallel to the curve. An emergency

depressurization is also required for the violation of PS

P. Additionally,

IAP-2 directs EAL entry at the highest level indicated by the conditions.

cc

.

CORRECT: The given conditions are 7 psig and 7 minutes from

violating the PCPL Curve. IAW EOP-4, venting of primary containment

is required prior to exceeding PCPL. General Emergency EAL 3.1.3 is

applicable when primary containment venting is required due to PCPL.

Without an available reference (EAP-4 Att. 1) to make a specific PAR,

this would be a conservative decision on the operators part; with

answer d being a subset of c.

Technical

Reference(s):

IAP-2, EAP-4 (and Bases)

EOP-4, EOP-4A, EOP-11

Proposed references to be provided to applicants during

examination:

IAP-2 Attachment IAP-2.1, EOP-

4, 4A, and 11

NRC Resolution - Q. #40

In regard to answer D (the original correct answer):

The staff recognized that the applicants were not provided with the necessary reference, EAP-4,

Att. 1, to determine the correct answer. The staff also recognized that per station management

expectations and the license operator training program, PARs will not be made without first

referencing EAP-4.

The NRC staff reviewed the original licensee justification, references noted above, the licensees

post exam comments, and found that answer D, Declare a GE. Evacuate a 2 mile radius and

miles downwind, was correct. The staff determined that answer D remains the correct

answer.

In regard to answer C (the proposed additionally correct answer):

The staff recognized that the applicants were not provided with the necessary reference, EAP-4,

Att. 1, to determine the correct answer. The staff also recognized that per station management

expectations and the license operator training program, PARs will not be made without first

referencing EAP-4.

The NRC staff reviewed the original licensee justification for C being an incorrect response,

the references noted above in support of that determination, and found that answer C,

Declare a G

E. Evacuate a 5 mile radius and 10 miles downwind, was NOT supported by the

references. The licensees post-exam statement that the answer was also appropriate because

it was a conservative response does not make the response correct in accordance with station

procedures. No procedural justification was provided by the licensee in regard to a conservative

response being acceptable for a PA

R. Therefore, the staff determined that answer C was NOT

correct.

In regard to answers A and B:

Based upon the original staff review and post-exam review of the question, it was determined

that these answers remain INCORRECT. (No change from original submittal.)

Conclusion

The NRC staff determined that the ONLY correct answer, based on procedural references, was

Answer D. The fact that C may be a more conservative decision did not make it a correct

answer. The staff recognizes that the licensee inadvertently failed to provide the applicants the

reference required to determine the correct answer and that prior to making a PAR

determination a referral to the reference was required by training and station management

expectations. No procedural justification was provided by the licensee in regard to a

conservative response being acceptable for a PAR.

Based on the fact that the procedure reference to determine the correct answer was not

provided to the applicants, the NRC staff has determined that the question should be deleted

from the exam. The licensee comment to accept both C and D as correct is denied.

SRO Question # 62 (Licensee Comments Highlighted)

An Equalizing Charge is in progress on Alpha Station Battery. MCC-253 is lost midway through

the charging cycle, resulting in the loss of:

Alpha Air Handling Unit 72 AHU-30A

Alpha Exhaust Fan 72FAN-46C

Alpha Recirculation Fan 72FAN-31A

The correct course of action, relative to Alpha Station Battery / Ventilation, is to:

a. Initiate actions to begin lining up emergency ventilation to Alpha Battery Room in

accordance with AOP-58 Station Battery Room Emergency Ventilation

b. Open Fire Dampers 72FD-3 and 72FD-6 to cross-connect Alpha and Bravo Supply and

Exhaust Fans in accordance with OP-33 Fire Protection

Answer Key:

c.

Post-Exam

Evaluation

Recommendation:

Accept both c and d as correct responses.

Challenge Issue:

Stem Clarity - As worded, both c and d are correct responses. The initial

operator action, as detailed in the attached copy of ARP-HV-7A-05, is to

ensure that the standby exhaust fan is operating properly. Guidance to

determine proper operation, including power supplies and damper

positions, would be found in OP-59A. The action to utilize the ARP and

associated OP is appropriate, supported by station management

expectations, and is in accordance with training program objectives

concerning procedure usage.

Discovery of the failure of the standby Exhaust Fan to start would be made

as a result of the reference to OP-59

A. Upon recognition of this failure, the

subsequent, or ultimate operator action for the presented conditions would

be to secure the equalizing charge in accordance with the stated Precaution

in OP-43A. The following correction to the last stem statement will make c

the only correct response:

The correct ultimate course of action, relative to the Alpha Station Battery /

Ventilation, is to:

Candidate

Performance:

C.

of 5 Selected d while the remaining candidate selected a

Explanation:

D

CORRECT: OP-43A Precaution states Equalizing charges shall only be

applied to batteries while battery room ventilation is operating to prevent

hydrogen buildup. Therefore, the charge must be secured.

A.

Incorrect: AOP-58 actions are only warranted when a fire in one of several

possible locations causes the loss of Battery Room Ventilation.

B.

D.

Incorrect: Both Fire Dampers areProperty "Contact" (as page type) with input value "D.</br></br>Incorrect: Both Fire Dampers are" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., in fact, located in the supply and exhaust

lines. 72FD-6 does cross-connect the supply line, but is normally open.

2FD-3 is located in the Alpha-side exhaust, but does not cross-connect

and is normally open. Additionally, OP-33 does not address Fire Damper

positioning for the aforementioned dampers.

d.

CORRECT: Alarm response in ARP-HV-7A-05 directs the operators first

(priority) action to be to Ensure the standby Exhaust Fan (72FN-46A) is

operating properly. This action is independent of the cause-effect

relationship and/or condition. Guidance to determine proper operation,

including power supplies and damper positions, would be found in OP-59A.

Technical

Reference(s):

OP-43A, OP-59A, AOP-58

Proposed references to be provided to applicants during

examination:

NONE

NRC Resolution - Q. #62

In regard to answer C (the original correct answer):

Answer C states Initiate actions to begin lining up emergency ventilation to Alpha Battery

Room in accordance with AOP-58 Station Battery Room Emergency Ventilation.

The staff reviewed the supporting references and found:

1.

The loss of MCC-253, which was a given condition in the question stem, results in a loss

of power to both exhaust fans 72FAN-46A and 72FAN-46C. These are the only fans

available to provide exhaust ventilation from the battery room.

2.

In accordance with Lesson Plan SDLP-72B, Objective 1.04, the power supply to the

battery room exhaust fans shall be known from memory and without error.

3.

Procedure OP-43A, 125 VDC Power System, Rev.22, Precaution C.2.1. states,

Equalizing charges shall only be applied to batteries while battery room ventilation is

operating to prevent hydrogen buildup.

The staff also noted that the question asked the applicants to determine The correct course of

action, relative to Alpha Station Battery / Ventilation. In this situation, the applicants must first

recognize that power is unavailable to both exhaust fans. With that determination, the applicants

must then recognize that the action stated in Answer D, Ensure the standby exhaust fan starts

..., is a moot point. Therefore, with no exhaust fans available, the applicants must abide by

the procedure precaution and, as stated in Answer C, secure the equalizing charge as the

correct course of action.

Therefore, the staff determined that Answer C was correct.

In regard to answer D (the proposed additionally correct answer):

Answer D states, Ensure standby Exhaust Fan (72FAN-46A) for Alpha Battery Room starts

in accordance with OP-59A Battery Room Ventilation.

The staff reviewed the supporting references and found:

1.

The loss of MCC-253, which was a given condition in the question stem, results in a loss

of power to both exhaust fans 72FAN-46A and 72FAN-46C. These are the only fans

available to provide exhaust ventilation from the battery room.

2.

In accordance with Lesson Plan SDLP-72B, Objective 1.04, the power supply to the

battery room exhaust fans shall be known from memory and without error.

3.

Procedure OP-43A, 125 VDC Power System, Rev.22, Precaution C.2.1. states,

Equalizing charges shall only be applied to batteries while battery room ventilation is

operating to prevent hydrogen buildup.

The staff also noted that the question asked the applicants to determine The correct course of

action, relative to Alpha Station Battery / Ventilation. In this situation, the applicants must first

recognize that power is unavailable to both exhaust fans. With that determination, the applicants

must then recognize that the action stated in Answer D, Ensure the standby exhaust fan starts

..., is a moot point and would serve no purpose as a correct course of action to address the

situation given in the question stem. Additionally, because the equalizing charge is not secured,

the safety consequences of a hydrogen buildup in the battery room due to the ventilation loss,

would not be addressed and this answer would not constitute a correct course of action.

Therefore, the staff determined that Answer D was NOT correct.

In regard to answers A and B:

Based upon the original staff review and post-exam review of the question, it was determined

that these answers remain INCORRECT. (No change from original submittal.)

Conclusion

The NRC staff conducted detailed reviews of all references provided as well as the information

stated in the question stem. It was also noted that no inquiries were made by the applicants in

regard to this question during exam administration. The staff concluded Answer C was the

ONLY correct answer. The licensee comment to accept both answers C and D as correct is

denied.

RO Question # 9 (Licensee Comments Highlighted)

A common-cause failure has resulted in all 137 CRD Hydraulic Control Unit (HCU) Accumulators

becoming inoperable. Per the Technical Specification Bases, which of the following reactor

pressures is designated as the transition point between acceptable and unacceptable Control Rod

Scram Times?

e. 750 psig

g. 850 psig

Answer Key:

b.

Post-Exam

Evaluation

Recommendation:

Change Answer Key from b to d

Challenge Issue:

Answer Key Incorrect / Stem Clarity - The stem requests the candidate

to demonstrate knowledge between acceptable and unacceptable

Control Rod Scram Times and not necessarily control rod operability.

The original intent of the question was control rod operability as

described in the lesson material and TS 3.1.4 Bases in relation to

preventing fuel damage. However, with the introduction of the

inoperable accumulators to the stem of the question the candidates

interpreted the question based on TS 3.1.5. The Bases of TS 3.1.4

does not deal with inoperable accumulators, but the Bases of TS 3.1.5

does discuss how reactor pressure and accumulator pressure work to

perform the scram function. See attached Tech Spec excerpt.

The stem requests the candidate to demonstrate knowledge between

acceptable and unacceptable Control Rod Scram Times as they relate

to the scram function. This demonstration is based on the knowledge

of the Tech Spec Bases and how the accumulators and RPV pressure

are used to perform the scram function. (continued on next)

Challenge Issue:

(cont.)

The stem of the question states that all accumulators are inoperable,

therefore the scram function is relying on reactor pressure only.

Tech Spec Bases states that above 900# the scram function will be

performed using reactor pressure alone assuming the accumulators are

inoperable. However, less than 900# the function of accumulators, in

providing the scram force, becomes much more important and at even

lower pressures the scram function could become severely degraded.

Therefore, with the accumulators inoperable 900# is the transition point

between acceptable and unacceptable scram times.

Candidate

Performance:

of 5 selected d, 1 selected B and 1 selected c

B.

Explanation:

b.

Incorrect: Reference Tech Spec Bases 3.1.4 and SDLP-03a,

Figure 8 Accumulator to Reactor Pressure Scram Times.

Although 800 psig is the pressure below which reactor pressure

alone will result in insufficient scram times to prevent exceeding

fuel thermal limits during Design Basis Accidents and transients, it

is bound by the Technical Specification reactor pressure of 900

psig below which scram times may not meet requirements.

A.

Incorrect: Incorrect pressure. Although bounded by the specified

900 psig reactor steam dome pressure, no reference in Technical

Specifications, or Bases, to a reactor pressure of 750 psig being a

transition point for control rod operability.

C.

D.

Incorrect: Incorrect pressure. Although bounded by the specified

900 psig reactor steam dome pressure, no reference in Technical

Specifications, or Bases, to a reactor pressure of 750 psig being a

transition point for control rod operability.

d.

CORRECT: Reference TS 3.1.5 Bases. With one control rod

scram accumulator inoperable and reactor steam dome pressure >

900 psig, the control rod may be declared slow, since the control

rod will still scram at the required operating pressure but may not

meet required scram times. Thus, at reactor pressures less than

900 psig with an inoperable accumulator, further degradation in

scram performance and excessive scram times would result.

Technical

Reference(s):

SDLP-03A, Figure 8

T.S. 3.1.4 / 5 and Bases

Proposed references to be provided to applicants during

examination:

None

NRC Resolution - RO Question # 9

In regard to answer B (the original correct answer):

Answer B stated 800 PSIG. The staff pre-exam review of the references supported this as

the correct answer.

The additional reference provided by the licensee and reviewed by the staff, Technical Specification Bases 3.1.5, supports 900 PSIG as the correct value to be designated as the

transition point between acceptable and unacceptable control rod scram times. The staff also

noted that the question stem stated that all control rod accumulators were inoperable. This

would support the statement in TS bases 3.5.1 in regard to the reactor pressure limit at which

control rod scram times would be unacceptable in the event of one inoperable control rod.

Additionally, the stem was more focused on control rod scram times and not control rod

operability (the bases for the 800 PSIG).

The staff has determined that TS references do not support answer B as correct.

In regard to answer D (the proposed correct answer)

Answer D stated 900 PSIG. The staff pre-exam review of the references did not support this

as the correct answer.

The additional reference provided by the licensee and reviewed by the staff, Technical Specification Bases 3.1.5, supports 900 PSIG as the correct value to be designated as the

transition point between acceptable and unacceptable control rod scram times. The staff also

noted that the question stem stated that all control rod accumulators were inoperable. This

would support the statement in TS bases 3.5.1 in regard to the reactor pressure limit at which

control rod scram times would be unacceptable in the event of one inoperable control rod.

Additionally, the stem was more focused on control rod scram times and not control rod

operability (the bases for the 800 PSIG as stated in TS Bases 3.1.4).

The staff has determined that TS references support answer D as correct.

In regard to answers A and C:

Based upon the original staff review and post-exam review of the question, it was determined

that these answers remain INCORRECT. (No change from original submittal.)

Conclusion

The NRC staff conducted detailed reviews of all references provided as well as the information

stated in the question stem. It was also noted that no inquiries were made by the applicants in

regard to this question during exam administration. The staff concluded that Answer B (the

original correct answer) was INCORRECT and that Answer D should be accepted as the ONLY

correct answer. The licensee comment to accept only answer D as correct is accepted.

RO Question # 75 (Licensee Comments Highlighted)

A reactor startup is in progress, following a refuel outage, with the following plant conditions:

IRMs on mid-scale on Range 7

Average Reactor Coolant Temperature is currently 200° F and rising slowly

A Zone RB-1W (Reactor Building West Crescent) Fire Alarm is received. An NPO is quickly

dispatched to the location and reports significant heat, smoke, and flames. All AOP-28,

Operation During Plant Fires prompt operator actions are completed satisfactorily. Which

of the following accurately reflects the plants current Mode of Operation?

a. Mode 2: Startup / Hot Standby

d. Mode 5: Refueling

Answer Key:

c.

Post-Exam

Evaluation

Recommendation:

Accept both b and c responses

Challenge Issue:

Stem Clarity - The stem conditions indicate power in the heating range

with coolant temperature slowly rising from 200 degrees. It was

unintentional that the Exam Development Team exposed the

candidate to a heatup in progress. Assuming a nominal heatup rate of

degrees per 15 minutes (procedural target), 9 minutes of elapsed

time will result in exceeding 212 degrees; resulting in a Mode change

and making the b response correct. Without a specified timeframe

for completing actions, and with some candidates taking a safety

analyses (UFSAR) approach to operator actions, it is reasonable to

expect that at least 10 minutes could elapse between the receipt of a

fire alarm, dispatching operators to verify conditions, AOP-28

procedure entry and step execution. Likewise, completing these

actions in less than 9 minutes is also reasonable; making the c

response correct.

Candidate

Performance:

candidates selected b, the remainder selected c

Explanation:

c.

CORRECT: Initial conditions place the plant in Mode 2. With a

confirmed fire in Zone RB-1W, a Reactor Scram would be inserted

and AOP-1 will direct taking the Mode Switch to Shutdown;

resulting in either Mode 3 or 4 operation. With resulting Average

Reactor Coolant Temperature below 212° F, Mode 4 operation

would result.

a.

Incorrect: Plant in Mode 2 currently. If candidate fails to recognize

AOP-28 Prompt Action Reactor Scram, this would be the resulting

mode.

b.

CORRECT: With IRMs on Range 7 and resulting Average

Reactor Coolant Temperature at 200° F and rising slowly, it is

inferred that a heatup is in progress; and Mode 3 operation would

result in as little as 9 minutes. If procedural actions take 9

minutes, or more, then a Mode change would occur based solely

on Reactor Coolant Temperature.

d.

Incorrect: See above. Mode switch can be in Shutdown for

Mode 5 if vessel head not fully tensioned. If candidate fails to

recognize dependency on tensioning, this could be the resulting

mode.

Technical

Reference(s):

AOP-28

ITS (Mode Definitions)

Proposed references to be provided to applicants during

examination:

None

Learning Objective:

JLP-OPS-ITS02, EO 1.03 (As available)

LPAOP, EO 1.03

NRC Resolution - RO Question # 75

In regard to answer C (the original correct answer):

Answer C stated Mode 4: Cold Shutdown. The staff pre-exam review of the references

supported this as the correct answer.

The original justification for this answer was based on the alarm condition, entry into AOP-28,

Operation During Plant Fires, and the first prompt action stated at step 1.2.1, Manually

scram the reactor and execute AOP-1 concurrently. The staff took into account that a heatup

was in progress but noted that with the first prompt action step of AOP-28, the reactor was

scrammed. This action would mitigate the heatup. Therefore, being in Cold Shutdown

accurately reflected the plants mode of operation and was supported by plant references.

The staff determined that Answer C was correct.

In regard to answer B (the proposed additional correct answer):

Answer B stated Mode 3: Hot Shutdown. The staff pre-exam review of the references

supported this as an incorrect answer.

The original justification for this answer being incorrect was based on the question stem

statement that the prompt actions of AOP-28 were completed satisfactorily, the first of which

was to manually scram the reactor. The staff determined that the reactor scram would mitigate

the heatup and that Mode 3: Hot Shutdown would not have been achieved. Therefore, answer

B was incorrect.

The licensees comment makes the following assumptions in regard to achieving Mode 3: Hot

Shutdown, and therefore accepting answer B as correct

1.

A nominal heatup rate of 20 degrees per 15 minutes.

2.

A time frame of greater than nine minutes elapsing before AOP-28 actions are executed.

The staff reviewed the licensees comment and assumptions in support of answer B and also

noted that no questions were asked by the applicants during exam administration in regard to

the conditions stated in the question stem. As stated in NUREG 1021, Rev. 9, Appendix E,

Step 7, when answering questions do not make assumptions regarding conditions that are not

specified in the question unless they occur as consequence of other conditions. Because no

time frame was stated in the stem other than the word quickly and the fact that the initial

prompt actions ( including a manual reactor scram) were stated as complete, an assumption that

minutes have elapsed goes beyond what is given in question stem. There were no indications

in the stem that the actions required to be completed were delayed and there was no indication

in the question stem that a nominal heatup rate of 20 degrees per 15 minutes had been

achieved. Finally, with the prompt actions of AOP-28 complete, a manual scram would have

occurred mitigating any heatup and the plant would be in cold shutdown.

Therefore, the staff determined that Answer B was incorrect.

In regard to answers A and D:

Based upon the original staff review and post-exam review of the question, it was determined

that these answers remain INCORRECT. (No change from original submittal.)

Conclusion

The NRC staff conducted detailed reviews of all references provided as well as the information

stated in the question stem. It was also noted that no inquiries were made by the applicants in

regard to this question during exam administration. The staff concluded that only Answer C

(the original correct answer) was CORRECT. The licensee comment to also accept answer B

as correct is denied.